Privacy Policy of 6969 APP Service[KJ COMMONS K.K./ THE BEATS INC] (“ we ,” “ our ,” or “ us ”) recognizes the importance of data protection for our users (“ you ,” or “ your ”) and establishes this Privacy Policy of [6969 APP] Service (this “ Privacy Policy ”) to ensure the proper handling of your personal data in accordance with the Act on the Protection of Personal Information of Japan, the General Data Protection Regulation (the “ GDPR ”), the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “ CCPA ”), the Personal Information Protection Act of the Republic of Korea, and other laws and regulations applicable to the processing that we perform when providing the service (collectively, the “ Applicable Laws ”).Personal data we collect and process
We collect and process the following personal data in the context of our service:
Basic Information:
User display name
Location Data
Contact Information:
Email address
Account Settings Information:
Profile picture
Profile bio
Favorite music genres and artists
Emotional Sharing Data:
Daily emotional states (text input)
Music selections related to emotions
Emotional sharing history (date, type of emotion, sharing scope)
Usage History:
App usage frequency and duration
Interaction Data:
Message history with other users
Reactions to other users’ posts (likes, comments)
Followed users and followers
Technical Information:
Device information (OS, version, device model)
App crash reports
Login history and IP address
We collect your personal data listed above directly or indirectly from you in our relationship with you, including, without limitation, when you: (i) make your personal account for the service; (ii) access or use the service; and (iii) communicate with us for inquiries about the service.
You are required to provide us with certain personal data when you use our service.
Personal data that is mandatory is indicated in the relevant forms.
We are not able to provide our service to you if such data is not provided.Purposes of data processing
We use your personal data for one or more of the purposes indicated below:
to provide, maintain, and improve our services, including troubleshooting, analyzing data, testing, researching, and conducting statistical analysis and surveys;
to provide you with the services you request, develop new services, suggest features that are personally relevant to you, provide you with customized content, allow you to engage in the interactive features of our services, manage your account, provide you with tailored advertising, and send you promotional materials from us, our affiliates, and trusted business partners;
to ensure the safety and security of our services, business, and users;
to comply with applicable laws and regulations;
to protect and exercise our legal rights or defend against legal claims;
to resolve any issues that may arise when you use the services; and
to respond to your inquiries, notify you about changes to our policies and terms, notify you about changes or improvements to our services, and notify you about other services we offer.
We do not make decisions that may affect you legally or in a similarly significant manner based solely on automated processing.Legal basis for data processing
We will primarily process your personal data based on your consent to this Privacy Policy.
If you wish to withdraw your consent pursuant to the Applicable Laws, you may do so at any time by informing us of the withdrawal of consent to us through our contact channel that is specified in “10. Contact us” below.
However, the withdrawal of consent will not affect the collection, use, or disclosure of personal information you have already given consent to us.
Other than where justified by your consent, we will usually process personal data necessary pursuant to the Applicable Laws (i) for the performance of contracts executed with you; (ii) for ensuring compliance with our legal obligations; and (iii) for our legitimate interests (or those of a third party), provided your interests and fundamental rights do not override those interests.
We will not collect additional categories of personal data or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice thereof.Secure management of personal data
We use reasonable measures to help protect information from loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction.
We also take appropriate technical and organizational measures to protect and secure personal data and to prevent unauthorized access and disclosure.
For details on the security measures we take, please use the contact channel that is specified in “10. Contact us” below.Disclosure of personal data
We may disclose your personal data to the following persons and entities in order to achieve the purposes of processing:
KJ COMMONS K.K./ THE BEATS INC;
entities that provide services to us for a variety of business purposes, such as [monitoring security and performance, maintaining or servicing accounts, processing or fulfilling orders and transactions (including payments), hosting information, and auditing and processing data];
counterparties of substantial business transactions, such as a sale or transfer of company assets, merger, or consolidation; and
third parties to which we disclose your personal data to comply with applicable laws and regulations;
handle legal processes and litigation; respond to requests from public authorities;
address national security, law enforcement, and other issues of public concern.
When we provide your personal data to third parties, we put appropriate measures in place in accordance with the Applicable Laws, and they will only use your personal data as described in this Privacy Policy.International data transfers
We may transfer your personal data to outside your country of residence, including [Japan and the United States.]
These countries may not have personal data protection laws as comprehensive as those that exist in your country of residence, and the same level of protection as that set forth in the personal data protection laws in your country may not necessarily be guaranteed.
In such case, we will implement necessary safety management measures, including, but not limited to, obtaining consent from you and concluding data transfer agreements with transferees, pursuant to the Applicable Laws.
If the GDPR applies to the processing of your personal data, we will protect your personal data based on an adequacy decision regarding the transfer of your personal data to Japan and other countries where an adequacy decision has been given, or by entering into Standard Contractual Clauses (Article 46(2) of the GDPR) regarding the transfer of your personal data outside the European Economic Area.
If you would like to review the Standard Contractual Clauses, please visit here.Data retention
Your personal data will be stored securely in our data server or in the third-party’s data server.
We will strictly control access to the personal data and will review such access control from time to time.
We will not keep your personal data for longer than required for the purpose of which it has been processed, in accordance with the Applicable Laws or, in any case, to allow us to protect our or a third party’s legitimate rights and interests.
To determine the appropriate retention period for the personal data, we will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of the personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.Children
We do not knowingly collect or process personal data of users under the age of thirteen (13) without the consent of a parent or guardian.
Users under the age of thirteen (13) must provide their personal data to us only with the consent of a parent or guardian.
If we discover that we have collected the personal data of a user under the age of 13 without the consent of the parent or guardian, we will immediately take appropriate action.Your rights and choices under the Applicable Laws
Pursuant to the Applicable Laws, you may have several rights on our processing of your personal data, which may include, to request access to, correct, or delete your personal data, to restrict processing of your personal data, to ask for data portability, and to withdraw your consent to this Privacy Policy.
You are also entitled to object to the processing of your personal data in certain instances pursuant to the Applicable Laws.
When we receive a request based on your rights above, we will conduct all necessary investigations without delay and consider whether your request meets the criteria and condition to exercise such rights under the Applicable Laws.
If you wish to exercise your rights specified in this section, you can reach out to us through our contact channel that is specified in “10. Contact us” below.
You may also have the right to lodge a complaint with the relevant supervisory authority under the Applicable Laws.
In particular, in the member state of the EU where you have a habitual residence or place of work or where the alleged infringement of the GDPR took place.Contact us
If you have any questions or comments about this Privacy Policy, the ways in which we collect and process your personal data described above, or wish to exercise your rights under the Applicable Laws, please do not hesitate to contact us at:
[Contact form]: https://form.asana.com/?k=JYyxkdShxzhNpIe7-AlEcw&d=1200219325560295
Changes
We will review our processing of personal data as appropriate and may revise this Privacy Policy.
If we make any revisions, we will inform you by displaying them on our website or by other appropriate means, or notify you directly pursuant to the requirements under the Applicable Laws.Supplementary Provisions for Processing of Personal Information of California Residents
In addition to the provisions set forth above, the following provisions apply to the processing of the information that identifies, relates to, describes, references, and is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“ personal information ”) of users who are residents of the state of California in accordance with the CCPA.
Categories of Personal Information We Collect and the Parties Receiving the Information
We will collect and has collected in the last twelve (12) months, the following categories of personal information from you.
Further, we have disclosed the personal information collected in the last twelve (12) months to the receiving party indicated in “5. Disclosure of personal data” above.The following table:
Category
A. Identifiers
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
C. Internet or other electronic network activity information
D. Geolocation data
"E. Audio, electronic, visual, thermal, olfactory, or similar information"
"F. Sensitive personal information"For details on personal information we collect, refer to “1. Personal data we collect and process” above, for the business purpose and commercial purpose of personal information we collect, refer to “2. Purposes of data processing” above, and for the retention period of the personal information we collect, refer to “7. Data retention” above.
Your Rights and Choices under CCPA
The CCPA provides residents of California with specific rights regarding personal information.
If you are a California resident, the following describes your rights under the CCPA and explains how to exercise those rights.
(1) Right to access personal information
You have the right to request that we disclose certain information to you about our collection, sharing, disclosure or use of your personal information.
Once we receive and confirm your verifiable request, we will disclose the following information to you:
The categories of Personal Information we collected about you;
The categories of sources for the Personal Information we collected about you;
Our business or commercial purposes for collecting, selling, or sharing such Personal Information;
The categories of third parties with whom we share such Personal Information;
The categories of Personal Information that we sold, and for each category identified, the categories of third parties to whom we sold such Personal Information;
The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed such Personal Information;
and
The specific pieces of Personal Information we collected about you.
(2) Right to request deletion
You have the right to request that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions.
Once we receive and confirm your verifiable request, we will delete (and notify our contractors to delete the same) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our contractors in order to:
Complete the transaction for which personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
Help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the rights of other consumers to exercise their free speech rights, or exercise other rights provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
and
Enable solely internal uses that are reasonably aligned with consumer expectations based on the relationship between you and us; or
Comply with legal obligations.
(3) Right to request correction
You have the right to request that we correct any of your inaccurate personal information that we have collected from you and retained.
Once we receive and confirm your verifiable request, we will correct (and notify our contractors to correct the same), your inaccurate personal information.
We may deny your request for correction if we determine that the contested personal information is more likely than not to be accurate based on the totality of the circumstances.
(4) Right to opt-out of sale or sharing
We have not sold or shared personal information collected from you in the last twelve (12) months and it will not sell or share them in the future.
(5) Right to limit sensitive personal information
We have not used and disclosed and will not use or disclose sensitive personal information collected from you for any purpose other than the following:
To perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services;
To help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes;
For short-term, transient use (except those involving profiling or changes to the future consumer experience);
To perform services on our behalf; and
To undertake activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us.
(6) Non-DiscriminationWe will not discriminate against California residents for exercising any of their rights under the CCPA.
Moreover, unless permitted by the CCPA, we will not:
Deny the goods or services to you;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services;
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services;
or
Retaliate against an employee, applicant for employment, or independent contractor.
(7) Exercising rights for disclosure request, deletion request and correction request
To exercise your rights for disclosure request, deletion request and correction request described above, please submit a verifiable request to us by contacting us in the manner set forth in “10. Contact us” above.
Only you, a natural person or a person registered with the California Secretary of State that you authorize to act on your behalf, or a person who has a power of attorney or is acting as a conservator for you, may make a verifiable request related to your personal information.
You may also make a verifiable request on behalf of your minor child.
The verifiable request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information or an authorized representative;
and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond thereto.
Privacy Policy Effective: 07 10, 2025